422 F2d 1332 Todd v. Commissioner of Internal Revenue

422 F.2d 1332

70-1 USTC P 9317

Gordon B. And Elizabeth H. TODD, Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Appellee.

No. 624, Docket 34158.

United States Court of Appeals, Second Circuit.

Argued March 17, 1970.
Decided April 2, 1970.

Allen H. Gardner, Washington, D.C. (Morris, Pearce, Gardner & Beitel, Washington, D.C., of counsel), for appellants.

Stephen Schwarz, Attorney, Dept. of Justice, Washington, D.C., (Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson and Elmer J. Kelsey, Attys. Dept. of Justice, Washington, D.C., of counsel), for appellee.

Before MOORE and FEINBERG, Circuit Judges and BONSAL,1 District judge.

PER CURIAM:

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1

The decisions of the Tax Court denying petitions for redeterminations of deficiencies based on the disallowance of deductions claimed for interest payments to alleged loan accounts established by gifts to members of the taxpayers' family are affirmed on the opinion of Judge Mulroney, reported at 51 T.C. 987 (1969).

1

Of the Southern District of New York, sitting by designation